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3. Defendant denies paragraphs 6 to 25 of the
witness statement and Claimant is put to proof.
4. Paragraph 27 of the witness statement is
denied. Defendant avers that he has always
granted access to the Claimant and its
contractors upon being given reasonable
notice.
5. Defendant denies paragraphs 28 to 33 of the
witness statement and the Claimant is put to
strict proof
6. Defendant avers that he suffers from mental
health problems and is under the care of the
mental health team which the Claimant has
always been aware of and in breach of its duty
under section 15 and 149 of the Equality Act
2010. Defendant has on several occasions
complained to the Claimant about noise and
other antisocial behaviour by the tenants of
113 and 117 but Claimant
305
8 August 2017
Dated: 22/09/2017
failed or refused to investigate and/or take any
action which there was no possible reason
other than the Defendant's mental health
problems.
7. The Defendant respectfully requests the court
to discharge the injunction dated 8 August
2017.
Statement of Truth
Defendant believes the facts stated in this Defence
are true. I am authorised by the Defendant to sign
this statement.
Signed: “Yes”
Name: Emanuel Onwusim
Dated: 22/09/2017
VLS Solicitors
Gibson House
800 High Road Tottenham
London
N17 0DH
Ref: VLS/EO/H/CORDELL/17
306
CLAIM NUMBER: D02EDO73
IN THE EDMONTON COUNTY COURT
BETWEEN: